Impact assessment of possible revisions to the drinking water directive

1. Impact assessment of possible revisions to the drinking water directive Stakeholder consultation 6 May 2008 Malene Sand Jespersen, Manfred Wienhoven, Pernille Christensen COWI in association with Ecorys and DHI

2. The impact assessmentScope and objectives • Problems and objectives • Policy options and the baseline (no policy changes) • Assessing the impacts of the options • Comparing the options

3. The impact assessmentProblems and objectives • Article 11: review every five years • 2008 review aims to • Take into account recent trends and developments as formulated in e.g. the revised WHO guidelines for Drinking Water Quality (2004) • Take into consideration the 12 new Member States • (Take note of compliance problems as noted in the 2003 Drinking Water Seminar) • To assess this, work has been initiated: • EU Microbiologist Expert Group • Ad-how Working Group on Sampling for Compliance Monitoring • Study on Chemical Parameters • Commission/WHO study on DWSP

4. Policy options • No policy change (baseline scenario) • Revising the parameter list • Recommendations from the 2003 DWS • Introducing DWSP • WHO/EU study recommendations • Combining the introduction of DWSP with changes to the parameter list • The impact assessment aims to assess the social, economic, environmental and administrative impacts of the policy changes under consideration

5. The policy option - assumed changes to the parameter lists

6. Preparatory steps Document and describe the water supply system Hazard assessment and risk characterisation Optimisation and prioritisation of investment and asset management Identify control measures Validation of control measures/optimised treatment Define monitoring of control measures/acceptable performance Surveillance (external and internal audit) Operational monitoring Supporting programmes Responding to emergencies and incidents Procedures to verity that the plan is effective and will meet targets Support programmes Management procedures for normal and incident conditions Documentation and communication procedures Emergency and incidence response Approval of plan The policy option - assumed actions in regard to water safety planning

7. Methods and means of data collection • Defining the baseline and the policy options • Screening of impacts • Identifying the important impacts • Selection of case study countries • Netherlands, UK, Denmark, Lithuania, Czech Republic, Spain • Questionnaires/interview guides • Data collection (Article 12 Committee; country experts; and other stakeholders) • Calculation tool to calculate costs • Literature study • Analysis and conclusions

8. Challenges • Data and impacts are extremely site specific • No quantitative information could be obtained on health impacts • Health impacts relate mainly to the avoidance of outbreaks and statistics on outbreaks are very uncertain • Difficult to obtain relevant information on small supplies • In the case of DWSP it can be difficult to distinguish the impacts from the policy change under consideration from the effects in terms of providing better compliance with the existing Directive • May be argued that DWSP's main merit lies in the enhanced compliance • National water policies affect the impacts

9. The important impacts • Environmental • Water level impacts, energy use, chemicals' effects on recipient • Economic • Testing and sampling • Administrative costs to suppliers to carry out the risk assessment; to implement the system and to operate it (DWSP) • Administrative • Training and guidance (DWSP) • Reporting (lowering the reporting threshold) • Social • Health impacts

10. The analysis

11. No policy change does not mean "no change" • Assumes full compliance with the existing Directive - and this does not reflect the current situation • Must capture trends underway: • DWSP is put more and more into use • Of the 14 replies (17 in total though) received: Netherland, Norway, Hungary, Slovenia, Spain and UK have or will have legal stipulations in that direction or other incentives that leads to a high level of use of the concept • HACCP and ISO certification is also widely implemented - by law or on a voluntary basis • Assumes compliance with the Water Framework Directive • Where the study on the chemical parameters indicates that the majority of problems experienced relate to the quality of the raw water

12. The assessment set-up • We assume that: • Netherlands, UK and Spain will not experience costs as a result of an EU regulation on DWSP • In Lithuania and Denmark, we assume that a certain fraction of the larger supplies will implement DWSP independently of an EU intervention • Cost structures are similar for similar sizes in different countries - correcting however for differences in wage levels • Water Framework Directive is complied with • We do not consider: • Effects from climate change • Developments with regard to EAS

13. Assessing the impacts from changes to the parameter list • Changes in parameter list will result in increased costs in sampling. • Costs related to a change in parameter list vary between 0,1096-0,0007 cent/m3. • No direct effect between size of utility and costs per m3. However there seems to be a clear trend within countries so that the costs are highest in Denmark and lowest in the Netherlands (enterococci only) and fairly low also in Lithuania.

14. Assessing the impacts from changing the parameter list • If current limit values are complied with, the costs and the benefits will be small • Small increases/decreases in (laboratory) costs • Little effect on environment: • Treatment processes not affected, but supplies that have not introduced management of cyanotoxins may have to invest in additional treatment leading to additional costs/energy use • Backwash water amounts not affected

15. Assessing the impact from introducing DWSP • Cost estimates have been calculated on the basis of information provided by water suppliers in • Netherlands (2 large supplies) • UK (average for a very large water company) • Denmark (two large ones and 1 small one) • Lithuania (1 large one) • Information has been provided on: • Resource needs to carry out the risk assessment • Resource needs to prepare procedures • Resource needs for implementation • Investment costs have been disregarded - relate to compliance with existing directive only

16. Assessment of DWSP regulation • Unit cost estimates vary between 0.01 and 2.81 cent/m3 • An UK average indicates an order of magnitude of 0.03 cent/m3 • Costs appear to amount to less than 1 cent/m3 over the 20 year horizon apart from the small utilities • Costs pr. m3 are higher for smaller water suppliers • An estimate for a large supplier in a new Member State is in the order of 0.01 cent/m3 • Costs of developing guidance material and doing pilots in CR amounts to 133,000 EUR • Health benefits cannot be identified, but are argued to be among the main reasons for the steps taken already at national levels; and at the individual utility level • Environmental benefits are not identifiable, and the strongest argument may lie in a stronger and more targeted efforts to delivering compliance with the existing DWD

17. Combining the options - introducing DWSP and adapting the parameter list • No significant impacts from changes to the current list • For other parameters there can potentially be a significant impact for instance: • Cyanotoxins (limit values necessitate risk assessment and consequent, if necessary reservoir management - cost increase) • Endocrine disrupting compounds (risks related to potential sewage exposure - cost increase) • Disinfection by-products • lack of disinfection - involves no monitoring - cost reduction • May not be different from current directive (Table A of Annex II) • ….providing drinking water that is wholesome and clean

18. Comparing the policy options • Changes to the parameter list • Worth the effort as a stand-alone change? • DWSP • Costs are small • Benefits are manifold and include: • Better prioritised investments - also in the light of the costs to come in regard to • More proactive approach to complying with the essence of the DWD, i.e. delivering drinking water that is wholesome and clean • Health effects are argued to be a strong motivation (proactive rather than ex-post approach, avoidance of outbreaks) • Combining the options • Applies to the thinking of DWSP's risk approach to enhance the focus on other parameters that cannot be controlled through the setting of limit values alone such as EDC

19. In conclusion • Drinking water safety planning is an already observable trend • Drinking water safety planning is a good means of ensuring a well-founded prioritised investment strategy for DWD compliance • Drinking water safety planning can provide value-added in terms of enhancing the current compliance - through its proactive and risk-based approach • Drinking water safety planning can benefit from being combined with a revised parameter list that considers the options inherent in the risk-based approach

20. In conclusion (continued) • An effective implementation of the concept must take into account the need for: • Flexibility (Smaller supplies have fewer resources; and less financial means, Some countries have made steps already in that direction) • Efficiency (ensuring that the introduction of DWSP does not lead to Member States imposing unnecessary administrative burdens onto the water sector, in particular the smaller supplies • Time (The need for lead time to in order not to involve excessively high costs) • Training and guidance (In order to provide for experience-sharing and an effective implementation)

21. Lowering the reporting threshold • Questionnaire survey to investigate the reactions to a possible lowering of the reporting threshold from 1000 m3 to 100 m3: • Motivated in the understanding that most compliance problems relate to smaller supplies • Administrative costs can be substantial on some cases, and quite insignificant in others. • Spain, Latvia, CR, UK and Germany replies indicate administrative feasibility - reasonable cost implications • Hungary, Netherlands, Romania, Lithuania, Denmark, Norway, Greece indicates that cost increases can be quite substantial - some of the countries nevertheless support the idea